CG malls europe - Commerz Real

Commerz Real Estate Master FCP – SIF
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS AT DECEMBER 31, 2009
21. Income and withholding tax expenses (continued)
possible for CGM Lux 2 and CGM Lux 3 to apply for the Interest & Royalties Directive (“I&R Directive”) withholding tax
rates for Portugal effecting a partial refund of the withholding tax. Under the I&R Directive in principle no withholding
tax is levied. Portugal implemented a transitory regulation in connection to the withholding tax rates that approach step
by step to the I&R Directive. The withholding tax rates according to that transitory regime are:
(i) 10% until June 2009
(ii) 5% from July 2009 until June 30, 2013
(iii) Nil after 1 July 2013.
Furthermore, in case certain conditions are met it will be possible for CGM Lux 2 and CGM Lux 3 after elapse of the two
year holding period to apply for the refund of:
(i) 5% of the interest due until June 30, 2009
(ii) 10% of the interest due between July 1, 2009 and October 31, 2009
In order to take advantage of this option, the Management has decided to amend both loan facility agreements to allow
for a two year holding period of the interest payments of both companies.
The effects of the amendment of the loan facility agreements are as follows:
22. Deferred income tax
Deferred income tax assets and liabilities are offset when there is a legally enforceable right to offset current tax assets
against current tax liabilities and when the deferred income taxes assets and liabilities relate to income taxes levied by
the same taxation authority on either the taxable entity or different taxable entities where there is an intention to settle
the balances on a net basis.
The gross movement in the deferred income tax account is as follows:
Financial Statements
The movement in deferred income liabilities during the year, without taking into consideration the offsetting of balances
within the same tax jurisdiction, is as follows:
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